The Office of the Information and Privacy Commissioner (OIPC) determined that $1768.50 combined, for 3 Freedom of Information Requests is a reasonable cost estimate – no reconsideration was allowed by the OIPC. The estimated cost is now up to $1,876.50.

The Office of the Information and Privacy Commissioner (OIPC) determined that $1768.50 combined, for 3 Freedom of Information Requests is a reasonable cost estimate – no reconsideration was allowed by the OIPC. The estimated cost is now up to $1,876.50.

Since the original estimate, the cost of one of the FOIs increased by an additional $108 (I paid for that FOI). The total I’m now looking at is $1,876.50 with the other 2 FOI estimates included.

By Sasha Izard
Dec 13, 2025

George Carlin once said, “We don’t have rights, we just have temporary privileges.”

We don’t have freedom of information, we have costly information, when it suits the government of British Columbia.

See: Index of Exorbitant Cost Estimates Provided for Freedom of Information in British Columbia – CRD Watch Homepage

The reader may recall my previous articles on this subject:

BC Housing estimates charging an outrageous $1768.50 combined, for 3 Freedom of Information Requests to do with basic financial and other information regarding payments to a registered lobbying organization that represents development and real estate interests. – CRD Watch Homepage

BC Housing claims records don’t exist regarding a previous membership in a lobbying organization, but at the same time estimates charging me over $1000 to find information about that membership. – CRD Watch Homepage

BC Housing Launched a Quasi-Judicial Attempt to Deny me Access to Information. They Failed. – CRD Watch Homepage

BC Housing couldn’t deny me access to information, as they had tried, but they could make cost estimates that were far beyond the reach of the general public, as they did.

I made an official complaint to the OIPC to review the fee estimates provided by BC Housing. Much of the year passed before, I received the conclusion of the OIPC’s investigation.

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On Sept 3, 2025 OIPC investigator Lisa Fleischauer wrote to me:

Good afternoon Sasha,

I am writing to provide you with my preliminary findings on your fee estimate complaints (F25-00322, F25-00431 and F25-00432).

BC Housing has provided detailed rationale and calculations that support the fee estimates. Based on the information provided, the fee estimates appear to be reasonable and justifiable given the scope of the requests, the volume of responsive records and multiple business units involved to complete the searches and produce the responsive records.

In my view, the fee estimates comply with section 75(1) of the Freedom of Information and Protection of Privacy Act (FIPPA) and the prescribed Schedule of Maximum Fees from the FIPPA Regulations.

Based on the above, please let me know if you have any questions or anything you would like to add.

Additionally, I can prepare a findings letter regarding the fee complaint matters if you would like more detail on the section 75(1) analysis. Please note that BC

Housing will receive a copy of this letter and the compliant files will then be closed.

Please let me know on or before Friday, September 19, 2025, if you would like a findings letter. If I do not hear from you by this date, I will assume you do not require a findings letter and will close the complaint files without further notice to you.

Regards,

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I wrote back:

Hello,

Yes I would like a findings letter, with the breakdown of why the fees were not excessive for each component of each FOI request.

Thank you,
Sasha Izard

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On Sept 24, 2025 – Fleischauer provided the requested findings letter in regard to the 3 FOI estimates:

Fleischauer concluded:

“In summary and based on the above, I find that the fee estimates provided by BC Housing comply with section 75(1) of FIPPA. The estimates comply with the Schedule of Maximum Fees set out in the FIPPA Regulation, and BC Housing has demonstrated to me that the fee is reasonable and appropriate based on the volume of records and time required to fulfill your requests. Therefore, your complaint is not substantiated.

To continue with the access requests with BC Housing, your options are to either:
1) pay the associated deposit listed in the fee estimates, or
2) consider reducing the scope of your requests to reduce the fee.

This concludes my investigation, and I have now closed the files. By copy of this letter, I have advised BC Housing of the status of these files.

Sincerely,

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I wrote back asking how I can appeal the decision.

Fleischauer responded:

Dear Sasha,

A decision may be reconsidered when the circumstances indicate:

· It is necessary to correct a clerical error, an accidental error or an omission by the Investigator.

· The finding has resulted from a breach of natural justice or administrative fairness.

· Relevant issues were not addressed or fully resolved; or,

· New evidence or facts are brought forward that were not previously available to the individual seeking the reconsideration.

The reconsideration request can be sent to info@oipc.bc.ca.

Please note as I have outlined your appeal option, I will no longer be responding to any emails regarding this file.

Thank-you,

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On Sept 26, 2025

I wrote to the OIPC for a reconsideration of the decision:

Hello OIPC,

I am submitting the following FOI files for reconsideration, on the basis that it is necessary to correct an accidental error or an omission by the Investigator.

Re: Complaint – Fees

BC Housing Files: 292-30-12724, 292-30-12824, 292-30-12924
OIPC Files: INV-F-25-00322, INV-F-25-00431, INV-F-25-00432

I do not consider the fee estimates to be in the spirit of freedom of information.

The investigator has concluded that these estimates are allowed under FOIPPA on the basis that BC Housing estimated that it would take x many staff hours per FOI request to retrieve and deal with the necessary information to complete them. What is to stop BC Housing from making an estimate for those FOI requests of 10 times the amount of hours for the same FOIs, and that not also being allowed by FOIPPA?

If there is no limit on hours that can be estimated in such scenarios under FOIPPA, then I submit that the spirit of freedom of information is not upheld by allowing public officials to estimate amounts of hours to arbitrary amounts without actual prescribed limits to time estimates, that are in keeping with the spirit of freedom of information.

Why I consider that the investigator has made an error and omission in their findings, is that they did not look at efficiency, as a factor in generating the estimates.

Even if the least efficient routes were utilized I doubt the number of time needed would correspond with anything close to the estimates by BC Housing for each FOI request.

I would like to point out one in particular though, because I think it illustrates this the best: BC Housing File: 292-30-12824/ OIPC File: F25-00431:

It was for the following request that I had made for: “All records regarding the following membership that BC Housing had for the UDI Capital Region (regardless of whether or not it was actually paid for):

Capital Region: Secondary Associate II (1-49 employees), expiration November 1, 2024. Current Pricing $1000+GST. In particular, I would like to see all communications and records related to how this membership was setup initially.
Records related to earlier Capital Region Secondary Associate II memberships, specifically; that BC Housing had with the UDI Capital Region.

BC Housing and the OIPC investigator both concluded that the appropriate fee estimate for the information about this specific membership, including communications and records showing how it was set up and previous versions of this membership, equated to $1048.50. In other words the fee estimate for the information was a dollar and 50 cents less to get information about the history of this specific type of UDI membership held by BC Housing, than the actual cost of the entire membership itself. How does it make sense from the purposes of public accountability for a history and information about a membership to be attained, for that to cost practically the cost of the entire type of the membership itself?

As I mentioned, I do not consider that BC Housing, nor the OIPC investigator to have taken efficiency into account when looking for information about this membership. Rather than approaching the IT department for a blanket estimate of “all records”. They could have narrowed down the search significantly. BC Housing should have approached first the finance department, which from my experience with contacting BC Housing, BC Housing makes locating the finance department for a member of the public, and then finding relevant financial information from them when asked essentially impossible. BC Housing does not even have its finance department contact listed on their website. When I finally did locate the relevant department it was in a very roundabout way, by telephone, and even then with great difficulty they simply refused to provide information when requested by myself a member of the public, hardly an accountable organization in a democracy.

BC Housing by not approaching such issues from the angle of approaching their own finance department first, thus makes the process in finding the relevant information regarding payments as inefficient as possible.

I consider that to make this search efficient, it can be done by by narrowing down the possibilities in the search and thus made reasonable cost wise. To do this I consider that that BC Housing could approach the finance department to find when payments were made by BC Housing for the specific membership mentioned, and the source of those payments, and then having narrowed down first what the payments in concern was, and what were their dates, then search records according to those locations and time frame to the relevant departments and parties, to find the results in a manner that is efficient and cost effective. Such an approach should cut down the time dramatically, I would expect no more than $150 to complete the foi response in that scenario, given that 3 hours would already be included for free.

I did make a subsequent FOI request for information that was in this FOI request that narrowed down the scope of considerably.

It was BC Housing File: 292-30-3725 for: “Records of the business decision (and who was responsible for it), that led BC Housing to receive its first Secondary Associate II membership with the UDI Capital Region.

Date range: 2022-01-01 to 2025-01-01″

That search cost me nothing. Clearly the search time to locate the membership was not really an issue at all. BC Housing’s FOI response however, yielded no documents whatsoever, despite that I already had at that point proof of purchase of a UDI Capital Region Secondary Associate II membership with the UDI Capital Region during that time frame (as attained previously from BC Housing).

Using the Archive.org waybackmachine it appears that the UDI Capital Region Secondary Associate II membership category did not exist at all for any municipality prior to 2023.

Join UDI – UDI Capital Region
Member – Membership Application – Urban Development Institute

The following is a screenshot from the form to sign up for a UDI Capital Region membership taken in March of 2022:

Note, the secondary UDI Secondary Associate II membership did not exist at this point for the UDI Capital Region.

The UDI switched its memberships system in November of 2023 (making all memberships corporate as opposed to having personal membership categories), when it pulled down its branch websites including the UDI Capital Region website and created only one website UDI.org.

The UDI Secondary Associate II membership exists now and is posted on UDI.org:

Join UDI | UDI – Urban Development Institute

Therefore it seems the first existence of that membership category existed between only in the last few years would take very limited historical research on the part of BC Housing to find the relevant information about it and setting up the original payment for it.

As such, I do not consider that BC Housing, provided an appropriate fee estimate by estimating that it would take over a thousand dollars to find information about this membership including communications about it and records of how it was setup.

As I pointed out, the entire cost of the membership for which I have proof of payment for already from BC Housing was $1000 + GST at the time. While BC Housing has estimated that it would cost $1048.50 and to receive the requested information about that membership and BC Housing’s communications and records of it being setup initially, something that must have happened in during the last few years.

I request that the OIPC thoroughly review BC Housing’s cost estimates for this and the other FOIs in question, looking first and foremost to the concept of efficiency, and reconsider the findings of its investigator Lisa Fleischauer that this and the other estimates were appropriate cost estimates for a member of the public to receive the information requested about this membership and its history, and the other information requested in the other FOI requests.

Thank you,
Sasha Izard

Appendix: Proof of Payment from previous communications with BC Housing, of BC Housing’s UDI Capital Region Secondary Associate II membership:

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On Oct 2, 2025 I received a letter from the OIPC regarding reconsideration of the decision, to follow.

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On Dec 10, 2025

I received the OIPC’s final decision by the Director of Investigations
Trevor Presley, who decided finally that none of the grounds I had provided are grounds for reconsideration:

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I wrote back:

Hello,

Thank you for your response. I have confirmation now that the OIPC consider these over $1700 in fees for 3 FOI requests reasonable, and the public will be informed of this.

You wrote:

“The Investigator outlined why these three fee estimates were reasonable and noted that the public body had given you a chance to narrow your request to reduce the fee. Indeed your own submission above suggests that you did subsequently narrow your request and the fee was eliminated.” You misunderstood what I wrote, and I cannot fathom how you came to this conclusion.

No fee has been eliminated.

Your misunderstanding that a fee was eliminated is due to to your reading about a different FOI response (292-30-3725), which was not included in the 3 FOIs under consideration. In FOI 292-30-375 I included only part of the scope one of the 3 FOIs (292-30-12824), as mentioned in my letter calling for reconsideration. I noted that although that FOI 292-30-375 cost me nothing, I received no records in it, when records clearly should have been included, based on that I already had a proof of purchase from BC of the type of membership purchased by BC Housing that I was looking for in the FOI.

To get no fee in a different FOI request, and also get no records from the response, when there should have been records included, is not a vindication of this process. It shows how critically it has been flawed at every step of the way.

Thank you again,

– Sasha Izard

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On Dec 15, 2025 Trevor Presley

Dear Sasha Izard

Thank you for the email, I’m sorry you disagree with the decisions. Please note your avenue for appeal through this office has been exhausted. If you wish to appeal these decisions you should speak to your lawyer as the next step involves a judicial review through the BC Supreme Court.

As I have now advised you of your appeal option, we will no longer respond to correspondence regarding these matters.

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The OIPC’s verdict was final, BC Housing according to them, was perfectly within reason to estimate charging me $1768.50 combined for the 3 FOIs. (Even if none of this made an ounce of sense from my very reasoned perspective which was not provided consideration, as both times I provided supplemental responses, the book was shut as fast as possible by the OIPC).

And yet, the price has continued increasing…

On Nov 21, I received the following letter from BC Housing: